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Effective Date March 11, 2025
Spin Master® Privacy Policy
Spin Master Limited, (“Spin Master”, “We”, “Our” and “Us”) is committed to protecting Your privacy as a data subject (“You” or “Your”) and the secure processing of Your personal data and We strive to limit the processing of personal data as far as possible and do not collect personal data beyond what is necessary.
We take privacy seriously at Spin Master and this policy is designed to share the information we collect and how we use it. This Privacy Policy applies to Reading Club, which are part of the services (“Services”) that Spin Master offers.
Needless to say, all processing of personal data, including the collection, registration, storing and general handling is governed by applicable privacy legislation, including the General Data Protection Regulation (“GDPR”). Spin Master strives to make sure that the processing of personal data done by Spin Master, is done in accordance with applicable legislation.
We aim to apply the GDPR to everyone but if You reside outside the European Union and use Our services, We may apply additional standards to You as required by local law. To the extent that the California Consumer Privacy Act (“CCPA”) applies to You, the definitions in this privacy policy are to be read as follows: “personal data” includes “personal information”; “data subject” includes “consumer”; “controller” includes “business”; “processor” includes “service provider”, all as defined under the CCPA. For more information about the CCPA, please see Section 9.
As a service directed towards children, We also adhere to the Children’s Online Privacy Protection Rule (“COPPA”). To the extent that the COPPA applies to You, the definitions in this privacy policy are to be read as follows: “personal data” includes “personally identifiable information”; “processor” includes “service provider”, all as defined under the COPPA.
Spin Master Ltd hopes that you have as much fun playing our mobile games as we do creating them. Nothing is more important to us than your safety online and we do all we can to make sure that we protect your privacy.
The contact details to Our Data Protection Officer are:
Spin Master Ltd
Attn: Data Protection Officer
225 King Street West
Toronto, ON M5V 3M2, Canada
Should You have any questions related to privacy and/or Your rights, You can also contact Us at customercare@spinmaster.com or Our Data Protection Officer at DPO@spinmaster.com. Below You will also find detailed information on how We process Your personal data, on Your rights and how You can exercise them.
This privacy policy describes how We collect and useYour personal data when You are using Our services, playing Our apps or interacting with Us. It applies to all visitors of Our websites, end users(including paying and non-paying users, grownups and children) and Our social media channels.
Under the GDPR You have certain rights concerning Our processing of Your personal data. If You would like to access, correct, erase or limit the use or disclosure of any of Your personal data that has been collected and stored by Spin Master or exercise any other right under applicable data protection legislation, please notify Us at DPO@spinmaster.com so that We may consider and respond to Your request in accordance with applicable law.
Right of information: You have the right to be provided information concerning Our processing of Your personal data. This includes understanding the purposes of processing, the categories of personal data concerned, and who else might receive Your personal data.
Right of access: You have the right to obtain confirmation as to whether or not We are processing Your personal data and, if this should be the case, have access to Your personal data.
Right to rectification: You have the right to obtain rectification of inaccurate or incomplete personal data concerning You.
Right to erasure (“right to be forgotten”): Under certain circumstances, such as if the personal data is no longer necessary for the original purpose, if You withdraw Your consent, or if the personal data has been unlawfully processed, You have the right to obtain the erasure of Your personal data. However, this does not apply if Our interest in continuing to process Your personal data outweighs Your interest in having it deleted or if We are subject to a legal requirement to retain Your personal data.
Right to restriction: Under certain circumstances, such as if You contest the accuracy of Your personal data or if the processing is unlawful but You oppose erasure and request restriction instead, You have the right to obtain the restriction of processing.
Right to data portability: Under certain circumstances, such as when the processing is based on Your consent or a contract with You and the processing is carried out by automated means, You have the right to receive Your personal data in a structured, commonly used and machine-readable format and the right to transmit this information to another controller.
Right to object: Under certain circumstances You have the right to object to the processing of Your personal data. This includes but is not limited to the right to object in cases in which We process Your personal data based on legitimate interest (Article 6(1)(f) GDPR).
Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority if You consider that Spin Master’s processing of Your personal data infringes the GDPR or any other privacy legislation. For Canadian users you can file a complaint at the Office of the Privacy Commissioner of Canada. or if you live in the Philippines you can file a complaint at the National Privacy Commission, You can also lodge a complaint with Your own national data protection authority, please see list here.
Right to withdraw consent: If a processing of Your personal data is based on Your consent as set out in this privacy policy, You have the right to withdraw Your consent at any time.
Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You.
If you would like to review or delete your or your child’s information, please contact us at DPO@spinmaster.com.
In this Section, We describe the types of personal data that We collect or create. In Section 4 We describe for what purposes and which legal ground that We rely upon when We process Your personal data. For the purposes of this privacy policy, the term personal data shall have the same definition as it has under the GDPR.
User Information: Information about Your use of Spin Master’s apps - such as in-app generated events based on Your interaction with the app, error and crash reports.
Device Information: Information from Your device - such as device IDs, Android ID, IDFV, operating system, platform, screen resolution and similar information about Your device and device settings/usage, IP address (including Your approximate location).
Customer Information: Information from You provided to Us via Our customer support and/or service functions - such as first name, last name, email, age, Your issues and/or ideas.
In the table below We indicate:
Here is a general explanation of each legal basis to help You understand the table:
In the case of a legal dispute or other legal matter between You and Us would work together with Our external advisors to assess and manage the legal matter. We would however still be the controller of Your personal data. If there is a legal dispute or other legal matter We will process Your personal data relevant to the matter or dispute. In particular, this may include Your name, e-mail address, contact details and any actions, progress and purchases that You may have performed in the app.
The purpose of the processing of the data by Us would in this case be the effective and uniform handling of legal matters.
If the data processing concerns the conclusion or performance of a contract with You, the legal basis of the data processing is performance of a contract. If the data processing is based on a legitimate interest, the legal basis is Our legitimate interest in effectively and uniformly handling legal matters and disputes. In case of legally legitimate and binding obligations by authorized courts or governmental authorities the legal basis for disclosing data would be in connection with the respective laws that state the legal binding effect of the obligation.
The storage period for data processed for the purpose of handling legal matters, disputes or complying with legal obligations is governed by the relevant limitation period, so that We can sufficiently defend ourselves against claims, or by the relevant legal obligations to retain documents.
Storage permissions are optional, to enable You to save your current drawings to the device gallery.
We will retain Your personal data for 1 year.
For non-personal data used for analytics, instead of deleting Your personal data We may anonymise the personal data so that no direct or indirect identifiers remain and after such anonymisation We will store the information for 1 year.
For marketing attribution purposes, We keep Your personal data for 1 year.
For the purpose of customer support and services We will keep Your personal data for 1 year, unless You contact Us asking for a removal.
Spin Master may share Your information, including Your personal data which includes but is not limited to billing information or user names, with Our agents, contractors, or service providers who are hired to perform services on Our behalf. We may also share Your information with Our affiliates. We disclose necessary information to authorities such as the Swedish Authority for Privacy Protection and other authorities if We are required to do so by law, or under some circumstances if You have requested Us to do so.
We may use information to protect our company, our customers, and our websites. We keep the data that we collect about you for as long as necessary for the purposes set out in this Privacy Policy.
Service Providers - Processors
Description of the recipient: Group Companies. These Group Companies only have the right to process the personal data they receive from Us on behalf of Spin Master, i.e. data processors.
List of companies that We share personal data with:
Spin Master Toys UK Limited
Winter Hill House Marlow Reach
Station Approach, Marlow, England, SL7 1NT
Please see the privacy policy here.
Sago Sago Toys Inc.
171 John St 5th Floor
Toronto, ON M5T 1X3, Canada
Please see the privacy policy here.
Purpose and legal basis: This is required for Spin Master to be able to provide You with its services and functionalities. We have a legitimate interest in being able to access and provide these services and functionalities (Article 6(1)(f) GDPR). We ensure that the processing this entails is necessary to pursue that interest, and that Our interest outweighs Your right not to have Your information processed for this purpose. You are entitled to object to this processing, for reasons connected to the circumstances in Your particular case. Please see Section 2 for more information about Your rights.
In some cases Spin Master might transfer personal data outside the EU and EEA, so-called third countries. For Our transfers to the US, Canada and UK following conditions apply:
We also identify and use additional protections as needed for each data transfer. For example, We use technical protection measures, such as encryption and pseudonymization.
We are committed to protecting Our users’ personal data and are among other things using pseudonymization, encryption and user based access levels to protect Your personal data. We strive to take appropriate technical and organizational measures to ensure the protection of Your personal data.
Under California Civil Code sections 1798.83, “Shine the Light Act”, California residents are entitled to ask Us for a notice describing what categories of personal data We share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. Please note that We do not share Your personal data with any third parties or affiliates for their direct marketing purposes.
CCPA provides consumers who are California residents with specific rights regarding their personal data
Right to Access: If You are a California resident, You have the right to request, up to two times each year, access to categories and specific pieces of Your personal data that We collect, use and/or disclose.
Right to Delete: If You are a California resident, You have the right to request that We delete Your personal data that We collect, subject to applicable legal exceptions.
Right to Opt Out of Sale of Personal Information: As the term is defined by the CCPA, Spin Master does not sell any personal data.
To make a request regarding Your rights under CCPA as described above, please send an email to DPO@spinmaster.com or write to us, using the addresses above.
This privacy notice may be changed from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to You if these changes are material and, where required by applicable law, We will obtain Your consent. The notice may be sent to You by email to the last email address You provided Us with, by posting notice of such changes on Our sites and applications, or by other means, consistent with applicable law. The date of the last modification is stated at the top of this document.